G.R. No. 76649-51 - 20th Century Fox Film Corp. vs. Court of Appeals

Letter‐Complaint and NBI Investigation
On August 26, 1985, 20th Century Fox Film Corporation (“petitioner”) filed a letter‐complaint with the National Bureau of Investigation (NBI), alleging that various Metro Manila videotape outlets were unauthorizedly selling and renting copyrighted films in violation of PD No. 49.
The NBI conducted surveillance of the outlets identified by petitioner, confirming alleged piracy activities.

Application and Issuance of Search Warrants
The NBI filed three consolidated applications for search warrants against the video outlets owned by private respondents Barreto, Sagullo, and Ledesma before RTC Makati Branch 132.
On September 4, 1985, the RTC issued Search Warrants Nos. SW-85-024, SW-85-025, and SW-85-026, authorizing seizure of videotapes, recording equipment, television sets, and other paraphernalia described generally in the warrants.

Execution and Subsequent Proceedings
The NBI, accompanied by petitioner’s agents, executed the warrants, seized the items, and left an inventory with respondents.
Respondents moved to lift the warrants and return the seized items; on October 8, 1985, the RTC granted the motion, ordering the warrants lifted and the items returned through counsel.
Petitioner’s motion for reconsideration was denied on January 2, 1986. Petitioner’s certiorari petition to the Court of Appeals was dismissed, prompting the present petition to the Supreme Court.

Validity of Initial Warrants
Whether the RTC properly found probable cause to issue the search warrants, considering the constitutional requirement of personal knowledge and particularity.
Whether the absence of presentation of master tapes and reliance on NBI witnesses’ testimony invalidated probable cause.

Legitimacy of Lifting Warrants
Whether the RTC committed grave abuse of discretion or violated due process in lifting the warrants and ordering return of seized properties.
Whether the warrants’ general description of items rendered them constitutionally defective as “general warrants.”